When I appeared on my nomination back in December 2017, I was asked to be prepared for a legislative review by the spring of 2018, so I've been working really hard for the last two years to come up with some recommendations. And experience helps, because the more I get along, the more I think of other things.
What I've done is gone through the recommendations that were made back in 2012 and what the committee had gone through and recommended. I decided to take a value-based approach. The values I've enunciated are transparency, efficiency, clarity and fairness. There are different things that can be recommended, and I've come up with 11 recommendations that would enhance those aspects. They can be put into two categories, some with respect to registration and some with respect to compliance.
With registration, the first one that everyone knows about, and I've said it in this committee before, is eliminating the “significant part of the duties” threshold. It's very difficult to apply, and it's difficult for organizations and corporations to know when they've met the 20% threshold. If you look at the different charges that have been laid, these have always been for consultant lobbyist or lobbying while prohibited. It is difficult for them to interpret and, therefore, very often they possibly over-report, or I investigate, and it's 13% or 15%. That is the difficult one.
What I highly recommend is that it be transparent and that it be registration by default with very clear criteria. If you fit in those exemptions, then you wouldn't need to register. Of course, we need to have a balanced approach as well.
Interestingly—and as you may or may not know—British Columbia has just adopted a number of new recommendations. They have gone the approach.... Their law will be in force on May 4. I don't know if they chose that date specifically for a reason. What they are doing is to have registration by default. If you have fewer than six employees and spend fewer than 50 hours a year at lobbying, then you do not need to register. My recommendation would be—and I don't know if you want to hear my recommendation, but I will keep going—fewer than six employees, likely about eight hours and three months.... I find that allowing a full year before having to register is too long. I would highly recommend that within three months, if you meet the threshold, you register. If you ask for more than $10,000, you should be registering.
That's one aspect. The other one is the monthly communication reports. Right now they have to be oral and arranged by anybody other than the public office holder. To me, who organizes the meeting should not matter to Canadians, and whether it's arranged in advance should not matter. Those one-hour conversations while you wait for your plane together should matter. To me, that's an important one. Whoever is in the room while the lobbying is occurring should be named. That's another example of a recommendation.